Report Num. 23
12/05/2020
Regulation (EU) 305/2011
This article of the Regulation on European Assessment Documents (EAD) is a key article. The first paragraph of clause (1) states:
“1. Following a request for a European Technical Assessment by a manufacturer, a European Assessment Document shall be drawn up and adopted by the organisation of TABs for any construction product not covered or not fully covered by a harmonised standard, for which the performance in relation to its essential characteristics cannot be entirely assessed according to an existing harmonised standard, …….”
This article is complemented by Annex II of the Regulation, which sets out the procedure for adopting the European Assessment Document. Point 8 of this Annex provides for the preparation of a European Technical Assessment (ETA) by the technical assessment body that received the application, once adopted the EAD. The ETA will be the basis on which the manufacturer of the product assessed will issue the declaration of performance (DoP) and CE mark its product.
Article 19 applies to all type of construction products not covered by a harmonised standard, whether they are innovative products or simply products without a harmonised standard. All kinds of companies benefit from this article, both large corporations and SMEs which have an important presence. Its application is backed up by nearly 8.200 ETA issued in Europe.
Why is article 19 important? If it did not exist or could not be applied, manufacturers would only have one alternative: address to each one of the Member States where they want to place their product on the market and request a national approval or a national certification, as required. That is to say, knock on the doors of all the Member States where they want to market their product.
What do you have to do to use this access door? It is simple, contact a Technical Assessment Body, such as ITeC, and apply for an ETA for the product to be assessed. From this point on, the body that has received the request will carry out a consultation to the other EOTA bodies to confirm that the product suits the Regulation and to see if there are any particular requirements which could affect it in any of the Member States. Once the consultation is completed, the process established in Annex II is initiated, led by the body that received the application (the body responsible for the EAD), with the participation of the other bodies in the product area concerned, under conditions of confidentiality.
This process is reasonably agile – very agile when compared to the development and application of a harmonised standard. If an EAD that covers the product and its intended use already exists, an ETA can be prepared straight away and, therefore, to develop an EAD won’t be necessary. This latter option is notably faster than the first.
This instrument is advantageous for those companies – SMEs in general – which cannot afford to address all Member States where they want to market their products, because of the effort and economic cost that this entails.
European Commission
At the Technical Board meeting in December, the Commission representatives requested EOTA not to prepare amendments of EADs for those products not included in their scope which do not require any change in the assessment methods. In this way, all the process until the publication of the amended EAD in the OJEU is avoided and the number of EAD versions is reduced.
EOTA agreed to apply this new criterion by consulting the bodies of the product area concerned, when a technical assessment body receives a request for a product or kit.
Since the Technical Board in December, this criterion is being applied and, in parallel, the procedure and conditions for its implementation have been defined.
Although this criterion is not included in the Regulation, the Commission has considered appropriate to apply it – also in the harmonised standards developed by CEN – in order not to overload the necessary processes until CE marking, where this criterion applies.
EOTA considers that, for its application, the aspects related to factory production control specified in the EAD must also be checked.
EOTA
At the end of last year, EOTA signed a cross licencing agreement with the American assessment organisation ICC-ES allowing both sides to share the use of their technical specifications. This agreement will facilitate the marketing of our products in the United States market. ICC-ES develops similar documents to EADs and ETAs for products without a standard and, particularly, for new and innovative products.
ICC-ES develops two types of documents “Acceptance Criteria” and “Evaluation Reports”. The former lay down the criteria for assessing the products and the latter is the assessment of the product for which the manufacturer has requested its assessment.
This is an agreement between both organisations for the use of EADs and “Acceptance Criteria”.
For more information, see EOTA news
CSIL – Centre for industrial Studies, Milan, is completing the study “EADs and ETAs: Added value to the construction sector”, commissioned by EOTA. The objective of this study is to collect objective information on the strengths and challenges of the ETA route for CE marking products without a harmonised standard, as well as to evaluate its relevance in the construction sector.
Within the framework of this study, a survey was carried out which ended on April 17. This survey was aimed at manufacturers, associations and technical assessment bodies, to know their views on the added value of EADs and ETAs. Participation in the survey has been very remarkable.
333 responses to the survey have been received:
- 73 % from manufacturers
- 13 % from associations
- 14 % from technical assessment bodies
8 interviews have also been carried out to complement the analysis and to deepen understanding of the results.
The results of this study will support EOTA’s future activities and discussions on the review of the Regulation. The opinion of those who apply for ETAs, i.e. manufacturers, and of industry in general, is very important, as is that of technical assessment bodies, i.e. the ones developing EADs and ETAs.
While the pending first phase conversions complete their process – they are in the publication phase (see “Conversion of ETA Guidelines in progress or pending publication”) -, second phase conversions have been initiated for the EADs concerning four ETA Guidelines:
- EAD 040083-00-0404 (Conversion from ETA Guideline 004)
External thermal insulation composite system (ETICS) with renderings
- EAD 040914-00-0404 (Conversion from ETA Guideline 017)
Veture kits – prefabricated units for external wall insulation and their fixing devices.
- EADs 120093-00-0107, 120109-00-0107, 120110-00-0107, 120111-00-0107, 120112-00-0107, 120113-00-0107 (Conversion from ETA Guideline 032)
Expansion joints for road bridges
- EAD 090062-00-0404 (Conversion from ETA Guideline 034)
Kits for external wall claddings mechanically fixed
On April 10, EOTA called for participation of experts from European associations in the EOTA working groups of these EAD.
For more information, see EOTA news.
This call was also made in the first phase conversions.
First phase conversions consisted in adapting ETA Guidelines – developed under the Directive framework- to the principles and criteria of the Regulation and to EADs format, considering the Commission guidelines. The technical content of the ETA Guidelines has been maintained, making technical changes only when it was essential.
Second phase conversions are focused on those technical aspects observed during the first phase that need improvement or clarification. These works were already in process for some ETA Guidelines, for example ETA Guideline 001 on anchors (EAD 330232-00-0601), and now they have been initiated for the four EAD mentioned above.
Scope extensions and technical developments not foreseen in this 2nd phase will be developed by means of subsequent amendments of these EAD.
At present, there are eighteen EAD published based on ETA Guidelines, of which the modification of one has already been published. There have been no changes in this situation in recent months.
Relation of EADs published can be consulted on Report No. 22.
According to indications received, the Commission plans to publish EADs in the OJEU in June. Apparently, it is very interested in publishing pending ETA Guideline conversions.
At the Technical Board No. 27 the current status of fourteen conversions presently in progress was informed.
As indicated in the previous Reports, four different basic phases can be distinguished in the conversion process from the ETA Guidelines to EAD:
1st Elaboration and adoption by the working group;
2nd Adoption by EOTA – by the designated bodies;
3rd Comments of the Commission – including their consideration;
4th Publication – this may also include the comments of the Commission, in the final review of the EADs;
At this moment, all conversions are at the 4th phase.
Detailed situation of the conversions:
- EAD on structural sealant glazing systems (conversions from ETA Guideline 002 parts 1 and 3): comments received from the Commission at the publication phase are being addressed.
- EAD on external thermal insulation systems (conversion from ETA Guideline 004): after considering the Commission’s comments, it was sent to the Commission for publication on April 21.
- EAD on liquid applied roof waterproofing kits (conversion from ETA Guideline 005): after considering the Commission’s comments, it was sent to the Commission for publication on February 24.
- EAD on timber frame prefabricated building kits (conversion from ETA Guideline 007): after considering the Commission’s comments, it was sent to the Commission for publication on 20 December 2019.
- EAD on non-loadbearing permanent shuttering systems based on hollow blocks or panels of insulating materials and concrete (conversion from ETA Guideline 009): Commission´s comments at the publication phase have been considered; the revised EAD has been sent to all designated bodies, for confirmation.
- EAD on wood-based composite beams and pillar (conversion from ETA Guideline 011): final positive review, pending publication process.
- EAD on three-dimensional nailing plates (conversion from ETA Guideline 015): final positive review, pending publication process.
- EAD on prefabricated units for external wall insulation (conversion from ETA Guideline 017): see information in section “ITeC and the European Technical Assessment”.
- EAD on prefabricated wood-based panels bearing tensioned forces (conversion from ETA Guideline 019): after considering the Commission’s comments, it was sent to the Commission for publication on 4 October 2019.
- EAD on plastic anchors (conversion from ETA Guideline 020): sent to the Commission for the publication phase; pending Commission’s final review.
- EADs on watertight covering kits for wet room floors and or walls (conversion from ETA Guideline 022 parts 1-3): sent to the Commission for the publication phase; pending Commission’s final review.
- EAD on fire retardant products (conversion from ETA Guideline 028): see information in section “ITeC and the European Technical Assessment”.
- EAD on connectors for structural joints (conversion from ETA Guideline 030): Commission’s comments at the publication phase have been considered; it will shortly be sent to the Commission for publication.
- EAD on expansion joints for road bridges (conversion from ETA Guideline 032 parts 1-8): Commission’s comments at the publication phase have been considered; the revised documents have been sent to all designated bodies, for confirmation.
European Assessment Document-EAD
At the Technical Board meeting in December, the Commission representatives present announced that, during the first quarter of 2020, and no later than the end of March, green-lighted EADs would be published after being revised at the publication phase. This forecast has not been met. For this reason, and taking into account the time elapsed since the last publication, EOTA addressed a letter to Commissioner Thierry Breton for Internal Market, informing him of the situation and requesting that the publication of EADs be prioritised. At present, the Commission’s indications point to June for the next publication of EADs in the OJEU.
ITeC and the European Technical Assessment-ETA
- Conversion from the ETA Guideline for fire retardant products (ETAG 028)
After considering the Commission’s comments, the revised EAD was sent to the Commission for publication on 18 December 2019.
- Conversion from the ETA Guideline on prefabricated units for external wall insulation (ETAG 017) – work led by CSTB-ITeC:
Comments received from the Commission at the publication phase are being addressed.
The second phase of this Guideline conversion has just been initiated, with ITeC participation (see point three, section “EOTA”).
- Conversion of the ETA Guideline for façade cladding kits (ETAG 034)
EAD 090062-00-0404 “Kits for external wall cladding mechanically fixed”: reference published in the OJEU, dated on 16.11.2018, by means of the Communication 2018/C 417/07. The full text can be consulted in the section “Our Publications” of the EOTA website.
The second phase of this Guideline conversion has just been initiated, which is also led by ITeC (see point three, section “EOTA”).
In addition to EAD 090062-00-0404, ITeC has twelve EAD published in the OJEU and is currently working on a further fifteen, three of which are EAD amendments:
- one has been sent to the Commission for the publication phase
- five have already been adopted by EOTA and the corresponding ETA is now under preparation
- the remaining nine are at different stages of elaboration
Note: at this point, the conversion works from the ETA Guidelines to EAD indicated in the first item of this section, are not considered.
Between 21.12.2019 and 04.05.2020, ITeC issued nine ETA and has forty-seven in process. The issued ETAs correspond to the following five EAD (see EOTA website, “Our Publications” section).
- EAD 040287-00-0404, on kits for external thermal insulation composite system (ETICS) with panels as thermal insulation and discontinuous claddings as exterior skin.
- ETA 20/0246 Baumit CeramicSystem EPS, Baumit Ceramic System MW, from Baumit Beteiligungen GmbH.
- EAD 090034-00-0404, on kits composed by subframe and fixings for fastening cladding and external wall elements.
- ETA 09/0115 Kit PF-ALU-PL
- ETA 09/0117 Kit PF-ALU-CER
- ETA 09/0118 Kit PF-ALU-CLA
- ETA 13/0309 Kit PF-ALU-HTR
- ETA 13/0310 Kit PF-ALU-HPL
This five ETA from MECANISMOS, ANCLAJES Y SISTEMAS AUTOPORTANTES SL – MASA
- EAD 090062-00-0404, on kits for external wall claddings mechanically fixed.
- ETA 19/0750 WindWall Terracota TW18 – FTS 502B, from LOUVELIA FAÇADE SOLUTIONS SL.
- EAD 260009-00-0301, on processed bottom ash from municipal solid waste incinerators as type II addition for production of concrete, mortar and grout.
- ETA 17/0908 Pozzolanica Solena, from SOLENA SRL
- EAD 360001-00-0803, on ventilation systems made of mineral wool covered with film on outside and inside.
- ETA 20/0122 CLIMAVER® HVAC duct system, from SAINT-GOBAIN ISOVER.
Frequently asked questions
A significant number of European Assessment Documents (EAD) published in the Official Journal of the European Union (OJEU) cover products for building construction. However, a 15% of the EADs published cover products for civil engineering. Such a percentage may seem insignificant, but this is not the case of the products dealt with in these EAD.
ITeC EOTA Office has drawn the article “Products for civil engineering works in the European Assessment Documents”, which gives an overview of these products, describing their applications, including images which describe them as well as observations on relevant aspects.
Relevant meetings
- Technical Board No. 27, Brussels, 11 and 12 March 2020 (*)
- General Assembly of EOTA, Brussels, 29 April 2020 (*)
- Technical Board No. 28, Brussels, 10 and 11 June 2020 (*)
- Technical Board No. 29, 22 and 23 September 2020 (place to be defined)
- General Assembly of EOTA, Brussels, 10 December 2020
- Technical Board No. 30, Brussels, 15 and 16 December 2020
